Product origin and meat origin

Hi All

I had some discussions with my coleagues regarding obligativity of labeling  the product origin and poultry meat origin.

The product is deep frozen chiken nuggets produced in Romania with chicken from Romania, made for a client from Monaco. On the label all the information are translated into 4 languages.

In conformance with Reg 1169/2011 the origin of this product  is not a "must" for labeling.

Please help me, to understand if some regulation sad it must be labeled, because my coleagues say it must and the client dont want to labeled. The client want only to label the healt mark of the producer and the distribuitor  contacts and adress.

Many thanks

Hi All

 

I had some discussions with my coleagues regarding obligativity of labeling  the product origin and poultry meat origin.

The product is deep frozen chiken nuggets produced in Romania with chicken from Romania, made for a client from Monaco. On the label all the information are translated into 4 languages.

In conformance with Reg 1169/2011 the origin of this product  is not a "must" for labeling.

 

Please help me, to understand if some regulation sad it must be labeled, because my coleagues say it must and the client dont want to labeled. The client want only to label the healt mark of the producer and the distribuitor  contacts and adress.

 

Many thanks

Hi Cristina,

I daresay it depends on the intended destination. Is this Monaco ?

Charles.C,

It will be Germany, France, Italy, Africa.

Hi Cristina,

This is not my product/customer area however I  can make some comments which are free to be corrected if wrong just so as to start the ball rolling. Anyone is welcome to dispute/correct/clarify the following but please provide justification.

IMEX of labeling issues, there are 2 frequent scenarios –

(a) a problem concerning an “area-wide” regulation such as EC

(b) no problem of type (a) but problem concerning an additional local regulation of the importing country.

I assume the OP refers to type (a), notably the EC  COOL (country of origin labeling) regs for poultry meat which came in to play 01april 2015 ? If otherwise perhaps Cristina would inform.

The latest documents I can see on the IT regarding such are this one on 21may 2015 –

http://www.themeatsi...abelling-plans/

and this Q/A faq of (presumably) post 01April –

Q-A new rules for labelling, 01april 2015.pdf   275.65KB   23 downloads

Based on the above, the COOL requirements  as per EC regs  seem to depend on either –

(i) whether the product is classified as “Processed” within the context of the 01 april 2015 regs or –

(ii) Possibly whether the product comes within the pre-existing requirements for “poultry” pior to 01april 2015. The latter situation seems to have been as -

MANDATORY AND VOLUNTARY LABELLING
Currently  mandatory  rules  on  origin  labelling  exist  for  several  sectors,  such  as
honey 3 , fruit and vegetables 4 , fish 5  (not fish products such as prepared or preserved
fish), beef and beef products 6 , olive oil 7 , wine 8 , eggs 9 , and imported poultry 10 .  
The FIC Regulation introduced mandatory origin labelling for fresh, chilled or frozen
meats  of  swine,  sheep,  goat  and  poultry,  whose  modalities  have  been  fixed  by
Commission Implementing Regulation (EU) No 1337/2013 11 .
Apart  from  these  rules  on  mandatory  labelling  of  origin  FBOs  are  free  to  label  at
their own initiative the country or region of origin, provided they fulfil the applicable
provisions of the FIC Regulation.

 

EC labelling_legislation, 20-5-2015.pdf   88.9KB   13 downloads

(note FIC =  Regulation  (EU)  No. 1169/2011.)

reg. EU No. 1169-2011.pdf   1.12MB   23 downloads

The contents of the (lengthy) FIC document appear to me to lack guidelines for deciding Y/N as to “where  failure  to  indicate  this  might  mislead  the  consumer  as to  the  true  country  of  origin  or  place  of  provenance  of  the Food…….”. (article 26,2a)

I assume the product in the OP is classified as “Processed” in which case it seems to avoid any mandatory (new) COOL  but I'm unclear whether still potentially included within the (semi-mandatory ??) 26,2a para. referred above ? . (unless this para. was auto-interpreted  as something to be quietly "skipped over"?)

Comments ??

PS - @Cristina - pls confirm if "Processed". are the "nuggets"  frozen raw breaded or just chunks of frozen raw chicken meat ? Is it "pre-packed"

Hi Charles.C

Many thanks for your informations. 

The nuggets are : Chopped and minced chicken meat, seasoned, formed, breaded, pre-fried, pre-cooked, deep frozen and pre-packed.

So, from all the information that I read , it seems that the origin of the product and of the poultry meat is not a " must" for labelling.

"Do the labelling rules also apply to processed meat preparations, such as meat pies, lasagne, etc?  The new labelling rules do not apply to processed meat or preparations, such as cured hams or meat pies. In that respect, the Commission has published a specific report on the possibility to extend mandatory indication of the country of origin or place of provenance for meat used as an ingredient (COM(2013) 755)"

Kind regards,

Cristina